Department of the Treasury - Internal Revenue Service
Form 12153 
(February 2020)       Request for a Collection Due Process or Equivalent Hearing

Use this form to request a Collection Due Process (CDP) or equivalent hearing with the IRS 
Independent Office of Appeals if you have been issued one of the following lien or levy notices:
•  Notice of Federal Tax Lien Filing and Your Right to a Hearing under IRC 6320,
•  Notice of Intent to Levy and Notice of Your Right to a Hearing,
•  Notice of Jeopardy Levy and Right of Appeal,
•  Notice of Levy on Your State Tax Refund,
•  Notice of Levy and Notice of Your Right to a Hearing.

Complete this form and send it to the address shown on your lien or levy notice. Include a copy 
of your lien or levy notice to ensure proper handling of your request.

Call the phone number on the notice or 1-800-829-1040 if you are not sure about the correct address 
or if you want to fax your request.

You can find a section explaining the deadline for requesting a Collection Due Process 
hearing in this form's instructions. If you've missed the deadline for requesting a CDP 
hearing, you must check line 7 (Equivalent Hearing) to request an equivalent hearing.

1. Taxpayer name (Taxpayer 1)

Taxpayer Identification Number

Current address

                      City                                State                         ZIP code

2. Telephone number and best       Home (      )        -                                       am. pm.
time to call during normal         Work (      )        -                                       am. pm.
business hours                     Cell    (   )        -                                       am. pm.

3. Taxpayer name (Taxpayer 2)

Taxpayer Identification Number

Current address
(if different from 
address above)        City                                State                         ZIP code

4. Telephone number and best       Home (      )        -                                       am. pm.
time to call during normal         Work (      )        -                                       am. pm.
business hours                     Cell    (   )        -                                       am. pm.
5. Tax information as shown on the lien or levy notice (if possible, attach a copy of the notice)

     Type of Tax  
                                   Tax Form Number  
     (Income, Employment,                                             Tax Period or Periods
                                   (1040, 941, 720, etc.)
 Excise, etc. or Civil Penalty)

Catalog Number 26685D                      www.irs.gov                                  Form 12153 (Rev. 2-2020)

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6. Basis for hearing request (both boxes can be checked if you have received both a lien and levy notice)
      Filed Notice of Federal Tax Lien               Proposed Levy or Actual Levy
7. Equivalent Hearing (see the instructions for more information on Equivalent Hearings)

      I would like an Equivalent Hearing - I would like a hearing equivalent to a CDP Hearing if my 
      request for a CDP hearing does not meet the requirements for a timely CDP Hearing.

8. Check the most appropriate box for the reason you disagree with the filing of the lien or the levy. 
See page 4 of this form for examples. You can add more pages if you don't have enough space. 
If, during your CDP Hearing, you think you would like to discuss a Collection Alternative to the 
action proposed by the Collection function it is recommended you submit a completed Form 433A 
(Individual) and/or Form 433B (Business), as appropriate, with this form. See www.irs.gov for 
copies of the forms. Generally, the IRS Independent Office of Appeals will ask the Collection 
Function to review, verify and provide their opinion on any new information you submit. We will 
share their comments with you and give you the opportunity to respond.

Collection alternative       Installment Agreement        Offer in Compromise     I Cannot Pay Balance

Lien                         Subordination                Discharge               Withdrawal
Explain

My spouse is responsible     Innocent Spouse Relief (attach Form 8857, Request for Innocent Spouse 
                             Relief, to your request)
Other (for examples, see page 4)
Reason (you must provide a reason for the dispute or your request for a CDP hearing will not be honored. Use 
as much space as you need to explain the reason for your request. Attach extra pages if necessary)

9. Signatures         I understand the CDP hearing and any subsequent judicial review will suspend the statutory 
                      period of limitations for collection action. I also understand my representative or I must sign and 
                      date this request before the IRS Independent Office of Appeals can accept it. If you are signing 
                      as an officer of a company, add your title (president, secretary, etc.) behind your signature.
SIGN HERE             Taxpayer 1's signature                                      Date

                      Taxpayer 2's signature (if a joint request, both must sign) Date

                       I request my CDP hearing be held with my authorized representative (attach a copy of Form 
                       2848)
Authorized Representative's signature  Authorized Representative's name           Telephone number

IRS Use Only
IRS employee (print)                                 Employee telephone number    IRS received date

Catalog Number 26685D                         www.irs.gov                         Form 12153 (Rev. 2-2020)

                                                                                                                     Page 3

Information You Need To Know When Requesting A Collection Due Process Hearing

What Is the Deadline for Requesting a Timely Collection Due Process (CDP) Hearing?
•  Your request for a CDP hearing about a Federal Tax Lien filing must be postmarked by the date indicated in the 
Notice of Federal Tax Lien Filing and Your Right to a Hearing under IRC 6320 (lien notice).
•  Your request for a CDP hearing about a levy must be postmarked within 30 days after the date of the Notice of Intent 
to Levy and Notice of Your Right to a Hearing (levy notice) or Notice of Your Right to a Hearing After an Actual Levy.
Your timely request for a CDP hearing will prohibit levy action in most cases. A timely request for CDP hearing will also 
suspend the 10-year period we have, by law, to collect your taxes. Both the prohibition on levy and the suspension of the 
10-year period will last until the determination the IRS Independent Office of Appeals makes about your disagreement is 
final. The amount of time the suspension is in effect will be added to the time remaining in the 10-year period. For 
example, if the 10-year period is suspended for six months, the time left in the period we have to collect taxes will be 
extended by six months.
You can go to court to appeal the CDP determination the IRS Independent Office of Appeals makes about your 
disagreement.

What Is an Equivalent Hearing?
If you still want a hearing with the IRS Independent Office of Appeals after the deadline for requesting a timely CDP 
hearing has passed, you can use this form to request an equivalent hearing. You must check the Equivalent Hearing box 
on line 7 of the form to request an equivalent hearing. An equivalent hearing request does not prohibit levy or 
suspend the 10-year period for collecting your taxes; also, you cannot go to court to appeal the IRS Independent 
Office of Appeals' decision about your disagreement. You must request an equivalent hearing within the following 
timeframe:
•  Lien Notice—one year plus five business days from the filing date of the Notice of Federal Tax Lien.
•  Levy Notice—one year from the date of the levy notice.
•  Your request for a CDP levy hearing, whether timely or Equivalent, does not prohibit the Service from filing a Notice 
of Federal Tax Lien.

Where Should You File Your CDP or Equivalent Hearing Request?
File your request by mail at the address on your lien notice or levy notice. You may also fax your request. Call the 
telephone number on the lien or levy notice to ask for the fax number. Do not send your CDP or equivalent hearing 
request directly to the IRS Independent Office of Appeals, it must be sent to the address on the lien or levy 
notice. If you send your request directly to Appeals it may result in your request not being considered a timely 
request. Depending upon your issue the originating function may contact you in an attempt to resolve the 
issue(s) raised in your request prior to forwarding your request to Appeals.

Where Can You Get Help?
You can call the telephone number on the lien or levy notice with your questions about requesting a hearing. The contact 
person listed on the notice or other representative can access your tax information and answer your questions.
In addition, you may qualify for representation by a low-income taxpayer clinic for free or nominal charge. Our Publication 
4134, Low Income Taxpayer Clinic List, provides information on clinics in your area.
If you are experiencing economic harm, the Taxpayer Advocate Service (TAS) may be able to help you resolve your 
problems with the IRS. TAS cannot extend the time you have to request a CDP or equivalent hearing. See Publication 
594, The IRS Collection Process, or visit https://www.irs.gov/taxpayer-advocate. You also can call 1-877-777-4778 for 
TAS assistance.

Note–The IRS Independent Office of Appeals will not consider frivolous requests. You can find examples of frivolous 
reasons for requesting a hearing or disagreeing with a tax assessment in Publication 2105, Why do I have to Pay Taxes?, 
or at www.irs.gov by typing “frivolous” into the search engine.

      You can get copies of tax forms, schedules, instructions, publications, and notices at www.irs.gov, at 
      your local IRS office, or by calling toll-free 1-800-TAX-FORM (829-3676). 

Catalog Number 26685D                                   www.irs.gov                        Form 12153 (Rev. 2-2020)

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What Are Examples of Reasons for Requesting a Hearing?
You will have to explain your reason for requesting a hearing when you make your request. Below are examples of 
reasons for requesting a hearing.
You want a collection alternative— “I would like to propose a different way to pay the money I owe.” Common 
collection alternatives include:
•  Full payment—you pay your taxes by personal check, cashier's check, money order, or credit card.
•  Installment Agreement—you pay your taxes fully or partially by making monthly payments.
•  Offer in Compromise—you offer to make a payment or payments to settle your tax liability for less than the full 
amount you owe.
“I cannot pay my taxes.” Some possible reasons why you cannot pay your taxes are: (1) you have a terminal illness or 
excessive medical bills; (2) your only source of income is Social Security payments, welfare payments, or unemployment 
benefit payments; (3) you are unemployed with little or no income; (4) you have reasonable expenses exceeding your 
income; or (5) you have some other hardship condition. The IRS Independent Office of Appeals may consider freezing 
collection action until your circumstances improve. Penalty and interest will continue to accrue on the unpaid balance.
You want action taken about the filing of the tax lien against your property—You can get a Federal Tax Lien 
released if you pay your taxes in full. You also may request a lien subordination, discharge, or withdrawal. See 
www.irs.gov for more information.
When you request lien subordination, you are asking the IRS to make a Federal Tax Lien secondary to a non-IRS lien. 
For example, you may ask for a subordination of the Federal Tax Lien to get a refinancing mortgage on your house or 
other real property you own. You would ask to make the Federal Tax Lien secondary to the mortgage, even though the 
mortgage came after the tax lien filing. The IRS Independent Office of Appeals would consider lien subordination, in this 
example, if you used the mortgage proceeds to pay your taxes.
When you request a lien discharge, you are asking the IRS to remove a Federal Tax Lien from a specific property. For 
example, you may ask for a discharge of the Federal Tax Lien in order to sell your house if you use all of the sale 
proceeds to pay your taxes even though the sale proceeds will not fully pay all of the tax you owe.
When you request a lien withdrawal, you are asking the IRS to remove the Notice of Federal Tax Lien (NFTL) 
information from public records because you believe the NFTL should not have been filed. For example, you may ask for 
a withdrawal of the filing of the NFTL if you believe the IRS filed the NFTL prematurely or did not follow procedures, or you 
have entered into an installment agreement and the installment agreement does not provide for the filing of the NFTL. A 
withdrawal does not remove the lien from your IRS records.

Your spouse is responsible—“My spouse (or former spouse) is responsible for all or part of the tax liability.” You 
may believe that your spouse or former spouse is the only one responsible for all or a part of the tax liability. If this is the 
case, you are requesting a hearing so you can receive relief as an innocent spouse. You should complete and attach 
Form 8857, Request for Innocent Spouse Relief, to your hearing request.

Other Reasons—“I am not liable for (I don't owe) all or part of the taxes.” You can raise a disagreement about the 
amount you owe only if you did not receive a deficiency notice for the liability (a notice explaining why you owe taxes—it 
gives you the right to challenge in court, within a specific timeframe, the additional tax the IRS says you owe), or if you 
have not had another prior opportunity to disagree with the amount you owe.

“I do not believe I should be responsible for penalties.” The IRS Independent Office of Appeals may remove all or 
part of the penalties if you have a reasonable cause for not paying or not filing on time. See Notice 746, Information About 
Your Notice, Penalty and Interest for what is reasonable cause for removing penalties.
“I have already paid all or part of my taxes.” You disagree with the amount the IRS says you haven't paid if you think 
you have not received credit for payments you have already made.

See Publication 594, The IRS Collection Process, for more information on the following topics: 
Installment Agreements and Offers in Compromise; Lien Subordination, Discharge, and Withdrawal; 
Innocent Spouse Relief; Temporarily Delay Collection; and belief that tax bill is wrong.

Catalog Number 26685D                         www.irs.gov                                          Form 12153 (Rev. 2-2020)